Tennessee
LLC
Website link to register:
https://sos.tn.gov/business-services
Naming conventions
PLLCs must describe the professional services provided. Must include “Limited Liability Company,” “LLC,” or “L.L.C.” Professional LLCs must use “PLLC.”
Licensing Requirements
Members must be licensed by the Tennessee Board of Medical Examiners. Proof of malpractice insurance required. Additional permits for controlled substance dispensing may be needed.
Required documentation for medical practices
Articles of Organization, Telemedicine Permits, Professional Licenses, Malpractice Insurance
Filing Fee: $300
Annual/Biennial Fee: $300
Additional Notes: Annual report due on LLC anniversary date. Minimum $300 fee, calculated based on $50/member.
Medicaid
Program Name: TennCare
Official Website: http://tn.gov/tenncare
Legislation: Tennessee passed SB 2443 in 2020, defining DPC agreements as not being insurance and exempting them from state insurance laws.
Private Contracting
Explicitly permitted; DPC agreements are recognized and not subject to state insurance laws.
Restrictions
No explicit restrictions for DPC providers; compliance with federal and state regulations is required.
Medicaid Program
Tennessee Medicaid, known as TennCare, provides health coverage to eligible low-income residents.
Notification Requirements
Notification required if Medicaid patients are not accepted for services.
Provider Enrollment Requirements
Providers must enroll with TennCare to serve beneficiaries directly or offer reimbursable services.
Enrollment Options
No "Ordering and Referring Only" status available.
Ordering, Referrals, and Testing
Non-enrolled providers may face challenges with Medicaid recognition for orders and referrals.
Designated PCP Restrictions
DPC physicians cannot act as Medicaid-designated PCPs.
Billing and Reimbursement
DPC practices typically do not bill Medicaid for services covered under private agreements.
Managed Care Plan Exemptions
Not specified.
Billing Clarity
Cannot bill Medicaid patients for covered services unless explicitly outlined.
CMS Guidance
CMS supports innovative models for primary care in Medicaid frameworks.
Opportunities for Collaboration
Opportunities may exist to collaborate with Medicaid Managed Care Organizations (MCOs) or state healthcare initiatives.
State-Specific Notes
Collaboration opportunities exist with Tennessee Medicaid Managed Care Organizations for DPC integration.
Dispensing Medication
Board of Pharmacy Official Link:
https://www.tn.gov/health/health-program-areas/health-professional-boards/pharmacy-board.html
State Licensing
Physicians must register with the Tennessee Department of Health and Board of Pharmacy for dispensing controlled substances.
Scope of Practice
Dispensing medications is allowed within a physician’s scope of practice; controlled substances require additional DEA registration.
Inventory Management
Maintain detailed inventory logs and secure storage for all medications.
Record-Keeping
Records must adhere to Tennessee state and federal HIPAA regulations.
Dispensing Standards
Labels must include patient name, prescribing physician, dosage, and usage instructions as per Tennessee law.
Controlled Substances
DEA registration and reporting to Tennessee’s PMP are mandatory for controlled substances.
Billing and Reimbursement
Physicians must comply with Tennessee-specific billing practices and federal Stark Law requirements.
Federal Compliance
Adherence to FDA, DEA, and OSHA standards is required for dispensing medications.
State Pharmacy Laws
Physicians must adhere to Tennessee Board of Pharmacy regulations for controlled substances dispensing.
Patient Consent
Patient consent is required prior to dispensing medications.
Insurance and Liability
Liability insurance must include coverage for medication dispensing activities.
Training Requirements
Continuing education for compliance with Tennessee controlled substances laws is recommended.
Audits and Inspections
Inspections are conducted by the Tennessee Department of Health and Board of Pharmacy, with penalties for violations.